The following speech is reprinted with the permission of its author, Perry Flint, Executive Editor - Air Transport World.

 Presented to the IATA Aircraft Maintenance '98 Conference and Exhibition, Dubai, U.A.E., November 3, 1998

            Thank you for that kind introduction.  It's an honor to be able to talk to such an international audience and I hope you will find my comments informative.  Although I bring an American perspective, I believe that the problems I am describing are global in nature, if only because of the importance to the world aviation community of events that occur in the U.S.A. and because the U.S. is so often on the leading edge of cultural transformations that ultimately occur elsewhere as well.

            When Frank Schreiber first approached me about speaking at this conference I was flattered, but also a bit uneasy.  I don't have a degree in aerospace engineering or experience in an airline maintenance department.  In fact, I've never worked for an airline or maintenance shop in any capacity.

            But Frank had something else in mind.  And as we discussed how I might be able to bring some insights to you, he pointed me in the direction of what I do for a living, which is to report and write about the workings of the airline industry.

            I suppose that kind of makes me a modern-day Daniel in the Lions' Den, given the way many of you probably feel about the news media.  But I don't feel like a Daniel and I think that the reason is because I am employed by Air Transport World Magazine and have been for the past 11 years.  At ATW, we have worked hard to earn the loyalty and trust of our readers and to become the industry's leading  trade magazine.  Every month, many of you in this room and 45,000 of your colleagues around the globe receive ATW, and judging from the renewal rates, are pretty happy with it.

            One reason is that we avoid knee-jerk reactions and lack a "follow the herd" mentality, particularly when it comes to safety issues.  As a monthly magazine we have the time and the inclination to bring a sober, thoughtful perspective to critical issues.  Granted, a four- to six-week lead time is not what we would typically think of as long-term, but CNN and the Internet have transformed journalism into a 24-hour-a-day scavenger hunt. In that environment, a month can seem like an eternity.

            It gives us the opportunity to step back from the latest "cause du jour" to look at the broader implications of public policy and safety decisions, to analyze where they originate and where they are likely to take us.  And when I do that, I have to admit that I'm pretty concerned about what is occurring in terms of the aviation safety agenda and the cultural, technological and societal changes that are driving this evolution.  I've no wish to dispute with those of you who believe you've seen it all before.   I know that in the past, safety agendas have been manipulated by individuals and groups.

            But in my 15 years of covering the industry, I have never experienced a period in which the influence of political forces was as overt and immediate in the safety process.  Never before has "safety" been so broadly defined, to encompass items having little relevance to what, a decade ago, we would have considered aviation safety.

            I use the word "political" broadly, to include not only governmental forces, but also the wide range of public and not-so-public interest groups that claim a right to define safety issues and to speak to them.  These can also be unions and manufacturers.  Even airlines can decide to promote an issue as safety-related, for reasons of competitive necessity or in order to forestall pending government regulation.        

            Furthermore, we live in a world in which emotions seem always to be just below the surface of things.  We are constantly being called upon to react, to feel, to respond to external stimuli such as the horrific imagery of a plane crash or the heart-breaking stories of victims' families.  The now common practice of  bringing relatives to a crash site and keeping them there for weeks at a time, when they should be at home finding comfort in friends and family, is a boon for television networks and accident lawyers. But it  also has helped to create an atmosphere in which sober reflection is simply impossible and the industry must respond helter skelter to each new crisis as ever more subjects come under the media microscope.

            I would not deny any of these groups a right to be heard.  But we seem to have moved beyond reasoned debate and discussion, and to paraphrase Alice in Wonderland, have adopted a "verdict first, evidence later" approach to safety regulation.  Those who attempt to slow down the process, to bring balance, often find themselves assailed as being "anti-safety," or guilty of "putting profits ahead of safety."  Rarely have governments moved so swiftly to address perceived safety inadequacies, even in instances where no direct harm can be shown to have occurred.

            Only three weeks ago, the world aviation community awoke to the stunning news that the Federal Aviation Administration had determined that insulation blankets in almost all of the world's 12,000 plus passenger jets will have to be replaced, because installed materials had been deemed to provide insufficient resistance to the spread of fire.  This decision, which will cost billions of dollars to implement, arose primarily out of findings in the ongoing accident investigation of Swissair 111.  Now, it may be that insulation ultimately is implicated as a contributing cause in the crash of the aircraft.  But let's consider that fires on-board aircraft are extraordinarily rare and there is no evidence of an injury or fatality attributable to an insulation blanket fire.

            Based on the evidence of new testing that insulation blankets are not nearly as fire resistant as was supposed, I don't think the airline industry disputes that something needs to be done. But FAA's decision to release this information in a statement to the news media before the establishment of a rulemaking process to review the issue, before any kind of cost/benefit analysis, which is required under U.S. law, I might add, and before even the drafting of new standards for insulation, represents a way of doing business that does not bode well for an industry that must already pay for items like Enhanced Ground Proximity Warning Systems, better pilot training and improved navigation and landing aids that will have a direct, positive bearing on reducing the accident rate.

            Given that FAA's position has become a matter of public record, reported across the globe by CNN and other news organizations, it will be very difficult for the industry and regulatory agencies to address this issue in a quiet, sober, reflective manner.

            How have we come to this state of affairs?  I believe that the roots of the present condition lie in the crash of ValuJet 592 in May 1996 and the vast media-directed outcry against FAA that followed.   The industry long has known that that accident occurred because an employee of a third-party maintenance company put a mislabeled box of oxygen generators into the belly of that airplane.  This was a clear violation of hazardous materials shipping procedures and rules. Had that person complied with the rules, the tragedy need never have happened.

            Outside the industry however, the belief was and probably still is widespread, that the accident occurred primarily because FAA failed to adequately supervise ValuJet's operations. This is owing in large part to a media-directed campaign on behalf of a former DOT employee who had just published a book highly critical of the agency.

            I believe the resulting frenzy of negative publicity had a crushing impact on the agency's sense of self-confidence and has led it to fundamentally re-evaluate its approach to regulation.  Quite simply, FAA has determined never again to be made a victim of media-manufactured outrage over perceived safety failings.  And we have seen since that accident how it has interpreted the word "proactive" to introduce vast new regulatory programs at immense cost and on extremely short notice.  All are beneficial, but it is by no means clear that they reflect the best use of available resources.

             Consider that the cargo hold smoke detection and fire suppression rules mandated after the ValuJet crash are costing the industry a lot of time and money, but will have little effect on safety because such accidents are exceedingly rare.  This, of course, pails in comparison to the massive cost associated with the anti-terrorism security measures imposed by the U.S. after the crash of TWA 800, an accident we now accept had nothing whatsoever to do with terrorism. 

            The ValuJet accident had another impact on the safety agenda.  It gave new blood to an organized labor movement that has never shied from using safety as a flag behind which to advance its interests. Let’s begin with an irony: For most of the world, the role of trade unionism in industry either is stagnant or in decline.  The only exception of note to this general rule, is the airline industry, where organized labor continues to attract new members while wielding enormous clout in the court of public opinion and at the bargaining table.  Those who doubt this need only look to recent events at Northwest, Air Canada, Air France, Philippine Airlines and All Nippon Airways.

            In defense of trade unions,  I recall a remark by a highly-respected airline industry leader who once told me, "Companies that get unions usually deserve them."  So if I take unions to task, I do so with the understanding that they are on the premises because employees no longer felt that they could get a fair deal without them.  Furthermore, airline unions, in particular the pilots' associations, have and continue to make outstanding contributions to aviation safety.

            Nevertheless, for the purposes of our discussion today, the relevant point is their growing ability to refocus the safety agenda into areas that have not traditionally been considered safety-related or to try to win through government regulation that which cannot be achieved at the negotiating table.  Because ValuJet was and still is primarily a non-union airline, and because of the circumstances surrounding the accident, it became a rally-point for unions, who did their best to implant in the public mind the idea that non-union airlines are by definition unsafe airlines.  This year the unions again tried to use the legislative process to limit the ability of U.S. airlines to access non-U.S. repair stations, except in emergencies.  In a global industry like aviation, a protectionist stance is unacceptable.  It would have had a negative impact on many of the airlines represented in this room.  But it was painted as a safety issue by the unions.

            This is by no means a tactic that is confined to the U.S.A.  I recently received in the mail a pamphlet from a group called the International Transport Worker's Federation warning that the "Asian crisis threatens aviation safety."  Why? Primarily because non-union airlines are cutting corners to save money and offer lower fares, according to the pamphlet.  Of course, the recent spate of air disasters in Asia largely have involved airlines with a long-history of organized labor and most occurred before the Asian economies collapsed. The ITF also repeats the old canard that competition "creates pressures which can seriously undermine safety," an argument that cannot be defended by comparing the safety records of those economically regulated airlines in Asia with the deregulated carriers in the U.S.

            Over the past few years, other items have been pushed to the fore as "safety" issues by unions. Generally these efforts can be exposed for what they are as long as they remain parochial enough to escape the attention of the mainstream news media.  Thus, when FAA proposed a massive rewrite of airline pilot flight duty/time regulations that would have added millions of dollars in new costs, without improving safety, the issue never caught on in the media.  As a result, airlines were able to put enough pressure on regulators to withdraw the rule quietly.

            But as lifestyle issues, such as tobacco smoking, enter the mainstream debate, they are finding their way into labor negotiations as safety issues, which is how they are presented to the media at large.  The debate on smoking, for example, inevitably becomes a discussion of passive smoke, and from there turns into a discussion of flight attendants' exposure to it as a serious health risk and gradually becomes transformed into a much broader health and safety issue for the traveling public.   Contributing to this problem is the popular perception that cabin air quality is generally poor and that cabin ventilation systems can cause a build-up of contaminants, such as cigarette smoke and contribute to the spread of disease, and other undesirable effects.

            Although numerous studies have shown these concerns to be unfounded, they nevertheless are accepted as fact by many.  A fair deal of cynicism surrounds the discussion.  Experts with whom I spoke say that the cabin air quality issue only surfaces around the time that flight attendants are due to negotiate a new contract.

            But I do not doubt that in the dark recesses of the FAA or at the Environmental Protection Agency, bureaucrats are even today toiling away in an effort to regulate cabin air quality.   When these regulations emerge, they will be presented as a safety issue, because they ostensibly address matters of public health.  There are many similar issues floating around today.  In each case the means by which they enter the mainstream of the safety debate is the same: first a so-called "problem" is identified.  As it receives widespread dissemination in the broadcast news media, and now via the Internet, it acquires a veneer of legitimacy and urgency that propels it to the top of the agenda.  Government, eager to be seen to be doing something, responds with a new regulation. 

            The industry also is partly to blame for this.  Cabin baggage, for example, is not primarily a safety issue; it is an operational issue.  As passengers bring more and more luggage into the cabin the ability to load and unload the aircraft promptly is compromised, hurting schedule integrity.  But because airlines are unwilling to act as their own policemen, they have allowed cabin baggage to be painted as a safety issue and have invited the federal government to regulate the practice.  The law of unintended consequences virtually guarantees that any regulation will create far more problems than it solves.  In fact, it already has.  As part of its evolving safety agenda, FAA has now assigned a full time cabin-safety inspector to every Major U.S. Airline.  I look forward to the first fine assessed against an airline for having a bag protruding from under a seat.

            You're probably wondering how an agency that is already hard-pressed to carry out its existing regulatory and air traffic responsibilities can afford to assign full-time inspectors to issues like in-flight baggage stowage, child safety seats and the like. The answer is that public opinion has been shaped to believe that these are important airline safety issues.  

            Today, an added dimension to this problem exists that gives me great concern.  Our society's ability to understand and accept the concepts of risk and risk measurement rapidly is disappearing.  Indeed, we are faced with a paradox: With each new advance in science, technology and medicine that improves the overall quality of our lives and increases our average life expectancy, comes a corresponding unwillingness to accept the ever shrinking amounts of actual risk in our personal lives.

            This affects aviation safety in a couple of ways.  The first is that we cannot discuss safety improvements logically and rationally.  It has become very difficult, for example, for FAA to publicly defend the key equation in any safety argument, which is the value of an individual's life in dollars, measured against the overall cost to society of each improvement in safety.   This figure is currently $2.7 million but I fear that we are very close to the point where the economic value of a human life will be deemed to be infinite--in practical terms we already may have taken this step--and  this industry will be expected to expend all available resources, in order to improve, by some imperceptible amount, the already enormous margin of safety in the airline industry, regardless of the overall consequences to society.

            Now, the corollary to this trend is that we have become statistical illiterates. Thus we are incapable of grasping that some risks are very, very real, while others have an insignificant impact on our lives.

            A case in point is the carriage of heart defibrillators on board aircraft.  From the amount of attention paid to these devices in the mass news media, one could only come away with the impression that thousands of people are dropping dead every year from heart attacks and other coronary events, while en route somewhere.   Now, I'm not saying that having defibrillators on-board aircraft is a bad idea.  But there is no way that the investment can be justified in terms of the actual number of annual in-flight emergencies that require such devices.  Nevertheless, the airline industry has made the decision that it is better to invest in these devices, which at $2,800 per unit are relatively cheap, than to deal with the negative media attention and inevitable lawsuits they would face, should they fail to have them available in a genuine emergency.

            How did defibrillators on aircraft come to be seen as an aviation safety issue?  Probably in part owing to aggressive marketing on the part of manufacturers of medical equipment who see a relatively large, untapped market for their devices. Partly it is owing to genuine concern at airlines that operate a significant number of extremely long flights over water and remote areas, where emergency landings are impossible and adequate medical facilities few and far between.  And of course, as these airlines introduced the devices it became paramount for their competitors to do the same.

            At least defibrillators represent a quasi-voluntary airline response to what the traveling public mistakenly views as a significant problem.  But what are we to make of the U.S. Department of Transportation's recent and fortunately unsuccessful effort to regulate the serving of peanuts on-board commercial aircraft flights operated to, from and within the United States?  This too, was advanced under the banner of safety: to wit, to protect from harm those persons who suffer from peanut allergies.

            Was there a public outcry in favor of regulation?  No. Are there any studies to support the position that the serving of peanuts represents a serious public health issue that needs to be addressed at the highest level of government?  Of course not.   But industries--and regulators--have become increasingly vulnerable to pressures that can be brought by tiny, well-organized special interest groups able to seize on a seemingly worthwhile health goal and generate favorable publicity for their cause.  The Internet has proved a Godsend to these groups, which now are able to organize and disseminate their views across the globe at virtually no cost to themselves.

            This, then is the shape of the new safety agenda.  It is driven by a combination of little known but media savvy interest groups, and the immense pressure on broadcast news media to generate higher profit margins which can only be achieved by showing ever more shocking, more outlandish and more entertaining stories. 

            Of course, even issues like peanut bans and defibrillators are relatively benign in the vast scheme of things.  But as aviation safety is redefined to include environmental issues--which are now viewed as public health matters--we are seeing more intrusions that actually have the potential to negatively affect safety.

            At Amsterdam's Schiphol Airport, for example, pilots are being asked to take off and land from runways selected for environmental considerations, not flight safety.  Now, what we're talking about here is noise pollution, so the risk of actual harm to humans or the environment is not quantifiable.  But we do know that 63% of all aircraft accidents occur during take-off, final approach or landing.  Yet regulators potentially are adding to the workload at this critical time.

            Obviously, this is one of the more outrageous examples of how the safety agenda has been reshaped in a manner that is degrading safety as those of us in this room understand it.  The broader picture that emerges, however, is one of a schism, between what aviation safety professionals view as the key issues to be addressed and the direction in which the safety agenda is often being pushed.  Although it might seem possible to proceed on two unequal tracks to arrive at the same goal, the reality is that resources are limited.  Even if every dollar of airline revenue was dedicated to the cause of safety, it is still not an infinite pot of money.  Thus, the industry's ability to tackle the two biggest problems, CFIT and loss of control accidents, is compromised to the affect that serious resources must be allocated to issues like carry-on baggage, disruptive passengers, cabin air quality, child safety seats, heart defibrillators, superfluous anti-terrorism measures and environmental health.   And I've not even touched on 16G seats!

            Identifying a problem is not the same thing as being able to solve it. We have all seen "the graph" showing that as traffic grows, so will the absolute number of accidents, unless the accident rate can be reduced.  But of course, long before the industry sinks to the level of one fatal accident per week, governments will impose such restrictions on operations as to reduce the rate of traffic growth to a fraction of what it is today. 

            The industry has embarked on several projects--the Commercial Aviation Safety Strategy Team and the Aviation Safety Alliance--that it hopes will be able to put it back on course in terms of focusing on the critical safety issues.  In the meantime, my plea to you is and it's admittedly self-serving-- is to help those of us in the responsible trade press do our jobs better, so that we can shine a brighter light into the darkness.